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Home My WebLink About07-7096 TERRI L. GILBERT, Plaintiff vs. DEREK S. GILBERT, Defendant 1. Plaintiff is Terri L. Gilbert, who currently resides at 261 South Ridge Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is Derek S. Gilbert, who currently resides at 31 Pine Drive, Manchester, York County, Pennsylvania, 17345. 3. Plaintiff is the Mother of the following child and seeks a custody order regarding the following child: NAME DOB/AGE ADDRESS Kirstien Gilbert 3/13/99 (8) 31 Pine Drive, Manchester, Pa. 17345 Mother and Father married on October 23, 1998 and were divorced on August 17, 2006. Father currently has primary physical custody of the child; however, he is currently scheduled to deploy to Korea. During the past five years, the child has resided with the following persons and at the following addresses: NAME Derek S. Gilbert and Terri L. Gilbert Derek S. Gilbert Derek S. Gilbert Terri L. Gilbert Derek S. Gilbert IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07- go er(o Civil Term ACTION IN BCE CUSTODY COMPLAINT ADDRESSES Incirlic AFB, Turkey Incirlic AFB, Turkey Las Vegas, Nevada 421 C. St. Apt 2 Carlisle, Pa. 17013 Las Vegas, Nevada Derek S. Gilbert 31 Pine Drive and paternal grandmother Manchester, Pa. 17345 DATES 2002 - 2004 2004 - 2006 2006 - 11/2/2007 6/5/07 - 8/19/07 8/19/07 - 11/10/07 11/10/07 - present The mother of the child is Terri L. Gilbert. She currently resides at 261 South Ridge Road, Boiling Springs, Pa. 17007. She is not married. The father the child is Derek S. Gilbert. He currently resides at 31 Pine Drive Manchester, Pennsylvania, 17345. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with Stephanie Heller and her parents. 5. The relationship of defendant to the child is that of Father. The defendant currently lives with his mother. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court other than as follows: The parties were divorced in Nevada and a divorce decree was issued which included custody provisions and provided that Father have primary custody of the child. Father is active milita and is current) scheduled to deploy to Korea. Neither Mother Father, or the child currently live in Nevada or have any intentions of returnin to Nevada. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Father is active military and will be deployed to Korea on December 7 2007 Father wants to leave the child with paternal grandmother during his deployment Mother does not agree and is seeking primary custody. This request is in the best interest of the child because Mother is best suited to provide for the child and provide stability for the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: I f - 2-L - a Respectfully submitted, d'a Adams, Esquire I.D No. 79465 6 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF _ cv rn . . O ?. CJ C' aq w fi f TERRI L. GILBERT, . Plaintiff vs. DEREK S. GILBERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. D 7. ?a 9(., Civil Term ACTION IN E- PETITION FOR SPECIAL RELIEF 1. Plaintiff is Terri L. Gilbert, (hereinafter referred to as "Mother") who currently resides at 261 South Ridge Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is Derek S. Gilbert, (hereinafter referred to as "Father"), who currently resides at 31 Pine Drive, Manchester, York County, Pennsylvania, 17345. 3. The parties are the natural parents of Kirstien Gilbert, date of birth, 3/13/99 age (8). 4. Mother and Father married on October 23, 1998 and were divorced on August 17, 2006. A divorce Decree was issued in Las Vegas, Nevada, which provided that Father would have primary custody of the child. 5. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES Derek S. Gilbert Turkey Derek S. Gilbert Las Vegas, Nevada Terri L. Gilbert 421 C. Street Carlisle, Pa. 17013 Derek S. Gilbert Las Vegas, Nevada Derek S. Gilbert 31 Pine Drive and paternal grandmother Manchester, Pa. 17345 DATES 2004 - 2006 2006 - 11/2/2007 6/5/07 - 8/19/07 8/19/07 - 11/10/07 11/10/07 - present 6. Father is currently living with the child and his mother in Manchester, Pennsylvania. He is active military and is currently scheduled to deploy to Korea on December 7, 2007 for a period of approximately one year. 7. Father has indicated that he is going to leave the child with paternal Grandmother once he leaves for Korea. 8. Mother wants primary custody of the child once Father is deployed. She is not in agreement that the child should remain with paternal Grandmother. 9. Mother's previous requests to Father for primary custody of the child upon deployment were denied. 10. Mother is requesting primary custody of the child as of December 7, 2007, which is the date that Father is scheduled to deploy. 11. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The child is familiar with Mother and her current living situation because the child lived with Mother from June 5, 2007 through August 19, 2007. (b) If Mother's request is not granted, there is a substantial likelihood that Mother could be denied physical custody of the child; it is in the best interest of the child to reside with Mother and not be denied contact with her. (c) Mother can provide stability to the child as she is not active military, has no plans to move, has a full-time job and a stable living situation. (d) Mother believes she is in the best position to care for the child and does not agree that the child should reside primarily with Grandmother. The child has only lived with Grandmother for several weeks and Grandmother does not have standing to seek custody independently at this time. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Respectfully submitted, Date: C ( • 2-C ` 0 ie Adams, Esquire . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF A VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: I t' 2-6 o'-) ern L. Gilbert, eti ion CERTIFICATE OF SERVICE AND NOW, this November 27, 2007, I, Jane Adams, Attorney for Terry L. Gilbert, hereby certify that a copy of the PETITION FOR SPECIAL RELIEF has been forwarded to the following party, by regular mail and by Federal Express to: Derek Gilbert 31 Pine Drive Manchester, Pa. 17345 FATHER 'Jane Adams, Esquire D. No. 79465 4 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER C? Q ?? C:.:-7 -...7 -r•? IT ; ;... C?J -"? l ` ; -- `- ? -?• ? , :- r .I'.. ?'`? . ? - C. %?T f?8 } ^'ti: TERRI L. GILBERT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-7096 CIVIL ACTION LAW DEREK S. GILBERT IN CUSTODY DEFENDANT ORDER OF COURT Friday, November 30, 2007 , upon consideration of the attached Complaint, AND NOW, directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, it is hereby 4th Floor, Cumberland Coun Courthouse, Carlisle on Thursday, December 20, 2007 at 8:30 A at for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the conciliator 48 hours prior to scheduled hearinp-. FOR THE COURT, y, Esq. By: /s/ Jacqueline M.--Verne Custody Conciliator The Court of Common Pleas of Cumberland County is required and reasonable ply ith the Americans accmodations with Disabilites Act of 1990. For information about accessible facilities contact our office. All arrangements available to disabled individuals having business before the court, please must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY TELEPHONE THE OFFICES OT HAVE AN ATTORNEY OR C T WHERE YOU COAN GETOLETO OR GAL HELP. FORTH BELOW TO FIND OU Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ty r- -)n?>,01? /d "Ilqw 4 o a I- 1 ?? 3 -ij .0 . , ?nm In/ NOV 3 0 TERRI L. GILBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. O ?- 90-9(. Civil Term DEREK S. GILBERT, ACTION IN Defendant ORDER OF COURT AND NOW, this 3 0A day of tAcxv? , 2007, upon consideration of the Attached Petition for Special Relief, the following Order is hereby issued: A."egxas#ie?- f $, The Court Administrator's office is directed to schedule an expedited conciliation conference to fully address the issues presented in this matter. cc: Derek S. Gilbert, father Jane Adams, Esquire, for mother (2? - My.", J. I cP mb114ZL 1/A4/0D 7 i? r, '?S ? i1 ? ??' ??fl lt?dZ ???, ?? .? -?- Q TERRI L. GILBERT : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW DEREK S. GILBERT NO. 2007-7096 Defendant : IN CHILD CUSTODY Prior Judicial Assignment: None. Conciliator Assignment: Jacqueline Verney, Esquire MOTION FOR STAY OF PROCEEDINGS UNDER SERVICE MEMBERS' CIVIL RELIEF ACT AND NOW, comes Movant, Derek S. Gilbert, by and through his counsel, Linda A. Clotfelter, Esquire, who files this Motion for Stay of Proceedings Under Service Members' Civil Relief Act, respectfully stating in support thereof as follows: 1. Movant is Derek S. Gilbert, (hereinafter referred to as "Defendant"), an adult individual and service member who, effective December 7, 2007, is deployed to Korea. He can be contacted through his agent appointed by Power of Attorney, Felicia E. Gilbert, who currently resides at 31 Pine Drive, Manchester, York County, Pennsylvania 17345. A true and correct copy of the Power of Attorney is attached hereto as Exhibit "A" and is incorporated herein as fully set forth. 2. Respondent is Terri L. Gilbert, Plaintiff in the above-captioned matter, who is an adult individual who currently resides at 261 South Ridge Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Defendant was recently served with a Complaint for Custody; a Petition for Special Relief; and an Order of Court scheduling a conciliation conference before Jacqueline M. Verney, Esquire on Thursday, December 20, 2007, at 8:30 a.m. A true and correct copy of the Order for the conciliation is attached hereto as Exhibit "B" and is incorporated herein as if fully set forth. 4. Defendant, who is presently on active duty in the Air Force, is protected by the Service Member Civil Relief Act (hereinafter "SCRA' ). 5. Pursuant to Section 202 of the SCRA (50 US Code APP. § 202) the court must, stay this proceeding for at least ninety (90) days upon application by a service member who has notice of the proceeding. Counsel for Plaintiff, Jane Adams, has indicated after a telephone conversation that she does not concur in this motion. 6. The initial 90-day stay is mandatory. 7. In support of this Motion and in compliance with the SCRA, Defendant has attached to this Motion the following exhibits: a. A letter written and signed by Defendant which states the manner of which his current military duty requirements materially affect his ability to appear and defend in this proceeding and it indicates the date upon which he will be available to appear. A true and correct copy of the letter is attached hereto as Exhibit "C" and is incorporated herein as if fully set forth; and b. A letter from Defendant's commanding officer stating that Defendant's current military duty prevents his appearance in this proceeding and also that military leave is not authorized at this time. A true and correct copy of the letter is attached hereto as Exhibit "D" and is incorporated herein as if fully set forth WHEREFORE, Defendant, Derek S. Gilbert, respectfully requests that this Court grant him the mandatory 90-day stay of proceedings pursuant to the Service Members' Civil Relief Act and grant such other relief as this court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Defendant VERIFICATION I, DEREK S. GILBERT, verify that the statements in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: /R G D DEREK S. GILBERT No. Uy4Y-Y ve , q. LUL'1 L.?arm rypYdAdK . SPECIAL-POWER OF ATTORNEY T"tSANM.ITAAYFOWiAOfAYTORNQY?A6FAAMAND6%CMWKMAVrtOTrrLElAtNNTEDs"t'ATL31c E.5ECTW1"4k8YAFFJiQM AVtNMZED1'OAF=VP-UOALAS$I$IAICCFROMTMFMWAAY$Ztvt .F2MALLAWEXVffTSAMMARYfOVIO(WAn f ytM I ANY AfQLR WT Of VMM. MMtANCE f0RMALITY a RKV DM THAT a fA43C ISW rMPOWEAS OF ATTORN$Y DY That IAW OF ANY STATLC0MMftWEA1,1M T41;1k1T0RY. MMCT.O? FOSSESSIOMOF THE WM SrATD. FfOEAAI LAW s?h s TMAT A WVTAaY MM10F ATTMV SMALL It OIrBi Tice SANS MALEMOCT As A ?OWM OF ATFORN[Y VMAM AND exeWW W ACf MWC2Wf M70 LAWS OF TK RRMSOCrION WMAC R M fRESRMIU. KNOW ALL PERSONS, that 1, DI re ?L g?C, liber# 'a legal resident of 10 ? and presently residing at %4D j, a SPECIAL POWER OF ATTORNEY, do hereby int address is 31 &&L De Kam.. PA 12M to act as follows, GRANTING unto my sail! Attormy full power- to-Act in loco parentis as ghneral guardian and to perform all acts necessary in connection with the exercise of said authority. Wither to do any and all acts necessary for mait3ataining the customary living standard Including, by way of dray of illustration bat not limitation, provision of lirrlug getarters, food, dothbC and outer necessities of life, and provision of an appropriate educational instltutioa approve by me. Provision of medical, sargicxl, dental care, and other acts normally associated with parental obUgatious and rights of the following names chtld(rea). DATE OF BiA'1''g /6 &wh t'%" SJtONSOR'S LAST [SOUR OF SSAM TERM>< UON: Unless sooner revoked of laminated by cue, this Power of Attorney shall become null and void ft+oiu and on the 11 day of e?re?4_ L« 20oi- _ M W SS WNMOF,1 have betenhoto $d my hand this the t8- day of S% ,t A:L, ' 200 ar Grantor's Agnoture STATE OF NEVADA COUNTY OF CLARK ) I, a Notary Pudic in and for Clark Co rada, caRify that the person whose mme•is sighed to this inswi alt was admowled ore me on this day of Wary Is Sgirature STATE OF NEVADA COUNTY OFCJA4M 1, a paralegal, autharized tike general powers of a Notary Public under the provisions of little 10, United States Code, Section 1044a and AFI 51-504, cactify the person whose name irst to this instrument was acknowledged before me on this ! day of 20 f Pai legai's S r AvM?o?? ti0ttry ?°t Acid 10 t;.3.C. 104. ,,Aht Uec. 4. 1991 2:WM Novapak No-0949 P. 17 TERM L. GILBERT IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA. V . • 2007-70% CIVIL ACTION LAW d r DEREK S. GILBERT 'S • IN CUSTODY ?- DEFENDANT ., 5 ? . . w m -10 ORDER OF COURT -? AND NOW, Frida y, November 30,2M , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequfte K Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December ?A, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference nary provide xm%nds for entry of a temporary or w manent order. The court bertby directs the parties to famish any and all existiag Protection from Abuse orders, Special Ret1d orders, and Ca Cody orders to the eoaeiliator 48 floors prior to scheduled bearing. FOR THE COURT. By* /s/ ere dice M. Y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled utdividuuals having business before the court, please contact our office. All u agernents roust be made at least 72 hours prior to any hearing or business before the court. You roust attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bamford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SSG Derek Gilbert, SSN 192-60-7546 PSC 3 Box 6781 APO, AP 96266-0067 December 6`h, 2007 TO WHOM IT MAY CONCERN: My current military duty requirements materially affect my ability to appear in the following manner: My tour of duty begins December 7, 2007 in Osan, Korea for 365 days with a leave of 30 days mid-tour which occurs in June. I am in the field every day of the week and I am unavailable to appear at my hearing on child custody. I have requested a leave of one week to attend this hearing in Pennsylvania, but have been denied by my commander. I need to be personally present in court on my Pre-hearing Custody Conference on December 20, 2007 to resolve issues in the dispute of custody of my daughter. I will be available to appear on or after June 9`h, 2008. %% A C DEPARTMENT OF THE AIR FORCE ?'"?' 51ST MUNITIONS SCKJADRON (PACAF) UNIT 2009 APO AP 96278-2009 I I Dtc 07 MEMORANDUM FOR '51 MUN'S/WXWKD FROM: 51 MUNI S,VC SUBJECT: Custody Relief 1. 1 am the commanding officer of Derek S. Gilbert, SSN 192-60-7546, his current duty status and mission impact prevent him from appearing in your court on December 211, 2(X)7. 2. I le has requested one week's leave for his court appearance, which I cannot auttuintx at this time. Y B. SPANN, Maj. I USAF Commander ¦ TERRI L. GILBERT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DEREK S. GILBERT NO. 2007-7096 Defendant IN CHILD CUSTODY CERTIFICATE OF SERVICE AND NOW, this day of December, 2007, the undersigned hereby certifies that a true and correct copy of the foregoing document was served upon the opposing parties by Facsimile and United States First Class Mail, postage prepaid addressed as follows: Jane Adams, Esquire 64 South Pitt Street Carlisle, PA 17013 Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER nda A. Clotfelter, Esquire ttorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Defendant •`'v' ?i ?, ??° ? : K" .?... ?., .r ..,m A TERRI L. GILBERT, Plaintiff vs. DEREK S. GILBERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2007 - 7096 Civil Term ACTION IN CUSTODY PETITIONER'S RESPONSE TO DEFENDANT'S REQUEST FOR STAY Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied in part, admitted in part. Some courts have refused to grant a stay under the S.C.R.A. (See Krutke v. Krutke. 693 N.W. 2"d 147 at 2, Wis. Ct. App. 2005) and other courts have held that the issuance of an S.C.R.A. stay does not bar temporary relief for the civilian parent. (See Lenser v. McGowan, 191 S.W. 3d 506, 507 (Ark. 2004). It is agreed that Plaintiff does not agree with the request for a stay. In the alternative, if a stay is granted Plaintiff is requesting that she be granted temporary physical custody. Mother requested this relief before Father was actually deployed. 6. Denied. 7. Neither admitted or denied; plaintiff has no information to confirm the veracity of the information contained in Plaintiffs exhibits. 8. The child is currently living with grandmother who is not cooperative in providing custody of the child to Mother. If a stay is granted, Mother is requesting an Order which would confirm that she has temporary physical custody pending any further Order of Court. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: Respectfully submitted, Ja Adams, Esquire I No. 79465 4 outh Pitt Street rlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF f • ATTORNEY VERIFICATION Undersigned counsel, Jane Adams, Esquire, hereby verifies and states that: 1. She is the Attorney of record for Terri L. Gilbert. 2. She is authorized to make this verification on her behalf. 3. The facts set forth in the foregoing response as known to her and not necessarily to her client. 4. The facts set forth in the foregoing response are true and correct to her to the best of her knowledge, information, and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ( ? f ) 0-J ne Adams, Esquire 7a a S. Pitt St. rlisle, Pa. 17013 Attorney for Terri L. Gilbert ?'"?.,. D ^43 ? ? ? 4 DEC 17 2DDla? TERRI L. GILBERT IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DEREK S. GILBERT NO. 2007-7096 Defendant IN CHILD CUSTODY ORDER G? AND NOW, this day of , 2001 upon consideration of Defendant's Motion for Stay of Proceedings Under Service Members' Civil Relief Act, it is hereby ORDERED that this proceeding shall be stayed for ninety (90) days from the date of this Order. THE COUR , J. L4&:--? sn4'"77V , J 1-MV , , It -"113t73U4e7d *7 ' ttU - 737Iz,w /,c(O? ?7Q • 00 J301QOZ A WIONi.1 q,W8d 3HI ?o DEC 1 9 2007 py J TERRI L. GILBERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2007 - 7096 Civil Term DEREK S. GILBERT, ACTION IN CUSTODY Defendant ORDER OF COURT AND NOW, this 49 day of At"44 beL- 2007, upon consideration of the Attached Motion, the following Order is hereby issued: n ag Th*' matter shall be continued until the Pov' day of 2008,at //•400 A.MAWin Cou oom No. of the Cumberland County Courthouse in Carlisle, Pennsylvania. J. cc: Linda Clotfelter, for Father Jane Adams, Esquire, for mother col ji'es m???sC zr'o7 3 S Z :OI NV I Z 33O LOOZ R14 0 TERRI L. GILBERT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DEREK S. GILBERT NO. 2007 - 7096 CIVIL TERM CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, this 4TH day of JANUARY, 2008, it appearing that this matter has been stayed pursuant to the Soldier's Civil Relief Act the hearing scheduled for January 2 2008, at 11:00 a.m. is continued generally. Edward E. Guido, J. Jane Adams, Esquire For the Plaintiff Linda A. Clotfelter, Esquire For the Defendant GOPI Es Mn I CLL :sld ! ? s ! # WV L- NVr ODOZ MAY 1 3 2008 TERRI L. GILBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-7096 CIVIL ACTION - LAW DEREK S. GILBERT, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 12`h day of May, 2008, the ninety day stay having expired and neither party have requested a Conciliation Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, E r ` v cq ine M. Verney, Esquire, Custo Conciliator C' m a CO?' C` r w' r n W